Good industry practice requires that process and plant modifications
should not be undertaken without having undertaken a safety, engineering and
technical review. This review should be traceable and identify changes
proposed to the following factors:

Process conditions;

Operating methods;

Engineering methods;

Safety;

Environmental conditions;

Engineering hardware and design.

A form of risk assessment should then identify what hazards have been
created by the change that may affect plant or personnel safety, and what
action can be implemented to reduce or eliminate the risk. Additional
hazards that may be introduced which need to be considered are fire,
explosion and loss of containment.

Changes may affect other parts of the plant which may be quite remote
from the source of the change. Therefore all parts of the plant should be
considered in undertaking hazard identification and risk assessments.

Factors that are crucial to the success and safe implementation of a
plant modification procedure include:

Corporate history;

Communication between different departments;

Recognition of authorised personnel;

Accurate recording and monitoring of changes to plant and process.

HAZOP

Various stages of Hazard and Operability Study are generally undertaken.
These are summarised in the following table:

HAZOP study

Description

1

Identify major hazards and check for availability of key hazard
data

2

Coarse HAZOP using flowsheet and block diagram

3

Full HAZOP on frozen P&I diagram

4

Check that all intended actions have been implemented, including
hardware and software

5

Pre-commissioning check including statutory requirement

6

Safety audit after a few months operation

These are equally applicable to plant modifications as new plant.
However, written procedures should be in place to determine what level of
HAZOP (if any) should be applied. These procedures should take account of:

The degree of hazard and extent of the change;

The worst case accident likely to arise as a result of the
modification,

Previous HAZOPs relating to the item being changed;

The appointment of a competent person (excluding the HAZOP chairman)
to decide the requirements for HAZOP.

A conventional hazard and operability study will identify potential
hazards, but gives no likelihood of an incident occurring, or the loss
suffered. The methodology has been developed to address likelihood and risk
to assist in resource and priority allocation. Where hazards are not
eliminated by actions placed during the HAZOP, Hazard analysis should be
employed to determine if the risk is acceptable.

Preliminary Hazard Analysis (PHA)

Preliminary hazard analysis is performed as the first step in a hazard
assessment. The essential stages of a systematic procedure to maintain a
safe manufacturing situation include:

Definition of the process / operating conditions / plant design;

Characterisation of the process with respect to chemical reaction
hazards;

Selection and specification of safety measures;

Implementation and maintenance of safety measures.

These stages should be applied:

During initial (research) process development work;

Prior to transfer to pilot plant scale;

Before full scale manufacturing is established;

When modifications to the process / plant are undertaken.

Operating procedures during change

Poor management and control of changes to plant and process often results
in increased risk to plant, people and environment. Consequently, control of
operating procedures during change is a critical task. Only authorised
personnel should amend existing operating procedures or issue temporary
operating instructions during plant or process changes. It is good practice
for the operating procedures to be authorised by representatives from
several different departments. These may include:

Operations;

Technical;

Health, Safety and Environmental;

Quality.

An assessment of change to risk should be an integral part of generation
of procedures. The degree of control of change will depend upon whether the
proposed change may be classed minor and major procedural changes

Commissioning procedures

Commissioning procedures are covered in more detail in the Technical
Measures Document on Operating Procedures.

The continued integrity of the plant needs to be upheld by adequate
maintenance, inspection and avoidance of unauthorised design or operational
changes. To avoid hazards caused by modifications, it is necessary that any
proposal for change be identified, and that the proposal is formally
authorised after, after technical investigation, by competent personnel of
senior status. Modifications should be designed, constructed, inspected,
tested and proved to have achieved the design intent and should be
maintained at least to the standard of the design criteria required by the
process.

Decommissioning procedures

The requirements for decommissioning will vary depending upon the nature
of the plant items to be decommissioned and the duty the plant items
fulfilled. Operating procedures should be provided for decommissioning of
hazardous plant in the same way as for commissioning. These procedures
should be subject to hazard review and risk assessment. General measures
that should be adopted for a common approach to decommissioning include:

Undertake removal of hazardous substance via a cleaning procedure to
ensure plant item is clean and empty with particular consideration where
there may be dead-legs where material may be trapped;

Consideration of the disposal of items which may be contaminated by
absorption of hazardous substances and chemical change;

Mechanically isolate plant item from other surrounding plant items by
physical disconnection or fitting of blanks;

Electrically isolate plant item from power sources by physical
disconnection.

Status of guidance

Plant modification and maintenance procedures are covered in general
guidance, however, no guidance is available that specifically covers plant
modification. Most companies usually adopt internally generated plant
modification procedures that have been developed through:

Corporate history and experience;

Good industry practice;

Input from Safety, Health and Environmental department;

Input from Operations department;

Input from Technical department;

Input from Engineering department.

Codes of Practice relating to Plant modification

HS(G)176 The storage of flammable liquids in
tanks, HSE, 1998.
Paragraph 23 to 27 give guidance on the requirements for HAZOP and Risk
Assessment. Paragraph 26 requires that risk assessments are carried out
for modifications and demolishing.
Paragraphs 158 to 161 give guidance on testing and commissioning.
Paragraphs 201 to 205 give guidance on decommissioning.

HS(G)30 Storage of anhydrous ammonia under
pressure in the UK : spherical and cylindrical vessels, HSE, 1986.
Paragraphs 98 to 117 give guidance on commissioning and decommissioning.
Paragraph 121 requires that a competent person authorise returning the
plant to service after modification.

LPGA Code of Practice 1, Bulk LPG Storage at Fixed Installations (Part
1, Part 2, Part 3 and Part 4), LP Gas Association.
Supersedes HS(G)34, The Storage of LPG at Fixed Installations. 1987,
HSE.
Part 3, Section 2.6 requires that modification or repairs for whatever
purpose, including change of duty shall comply with the design codes in
Parts 1 and 2.

HS(G)34 Storage of LPG at fixed installations, HSE, 1987.
Superseded by the above.
Paragraphs 172 to 191 give guidance on commissioning, decommissioning
and maintenance, including that modifications should be certified by a
competent person.